Filed 9/16/26 In re A.H. CA3
NOT TO BE PUBLISHED
California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for
publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication
or ordered published for purposes of rule 8.1115.
IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA
THIRD APPELLATE DISTRICT
(Yolo)
In re A.H., a Person Coming Under the Juvenile Court C105485
Law.
(Super. Ct. No. JV-2024-0204)
YOLO COUNTY HEALTH AND HUMAN
SERVICES AGENCY,
Plaintiff and Respondent,
v.
J.H.,
Defendant and Appellant.
Appellant J.H., father of the minor, appeals from the juvenile court’s combined 6-
and 12-month review order continuing reunification services to both father and mother.
(Welf. & Inst. Code, §§ 366.21, 395.)1 Father claims the juvenile court erred in finding
the Yolo County Health and Human Services Agency (Agency) provided him with
reasonable services.
1 Undesignated statutory references are to the Welfare and Institutions Code.
1
During the pendency of this appeal, the juvenile court granted the Agency’s
section 388 petition for modification and ordered return of the minor to mother with
family maintenance services to mother and discretionary services to father. The Agency
argues father’s appeal is therefore moot. We agree and will dismiss the appeal.
BACKGROUND
In September 2024, the minor’s family became involved with the Agency due to
domestic violence in the home causing the minor (then eight years old) to fear for his
safety. During that period, father and mother agreed to participate in three separate safety
plans and mother agreed to obtain a restraining order and a move-out order against father.
The parents, however, repeatedly violated the terms of those safety plans by staying in
the home together and engaging in domestic violence, and mother eventually requested
the restraining order against father be dropped.
The parents’ ongoing domestic violence, resulting in serious injuries to mother,
continued to strike fear in the minor and he struggled emotionally and socially in school.
In November 2024, the Agency filed a dependency petition pursuant to section 300,
subdivisions (b) and (c),2 took the minor into protective custody, and placed him with the
paternal grandparents, where he remained throughout the proceedings.
In late November 2024, the Agency referred both parents to Bobbie Stewart
Consulting for informal services including a domestic violence program and an anger
management program. The Agency also referred the parents to substance abuse testing,
parenting education, and mental health services. Since the inception of the dependency
matter, father claimed the allegations in the petition were untrue, stated the Agency’s
involvement with the family was “inconvenient,” denied any domestic violence in the
home, and minimized the impact of it on the minor. He repeatedly violated the terms of
2 The section 300, subdivision (c) allegation was subsequently stricken by the
juvenile court.
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the move-out and restraining orders by being in the home and having contact with
mother. As of December 2024, father had not begun any of the informal services and
continued to minimize the events in the home which led to the minor’s removal.
In March 2025, the juvenile court took jurisdiction over the minor, adjudicated
him a dependent child of the court, and ordered formal reunification services and
supervised visitation for the parents. Afterwards, the social worker met monthly with
father to provide gas vouchers and to discuss reunification services and court processes
and procedures.
Throughout the proceedings, the Agency provided, or attempted to provide, court-
ordered services to the parents. When the Agency learned father had been discharged
from his domestic violence and anger management programs, father explained that he did
not like being on camera and claimed he would not benefit from those services because
he “fixed all my … problems 20 years ago, and there is nothing they can teach me, I
already know everything she is saying.” As of June 2025, father had not signed a release
of information.
The minor’s mental health provider indicated she would like to integrate mother in
services and a plan would be discussed at the upcoming child family team (CFT)
meeting. The Agency discussed family therapy services with the parents at the CFT
meeting, but it was decided that the minor’s provider would assess whether it was
appropriate for the minor to participate since he was making good progress in his own
treatment plan. The minor was discharged from services in 2025, as he was stable, so the
Agency recommended the parents inquire of their respective therapists regarding the
provision of family therapy services, since the concern was focused on the parents’
relationship. For several months, the Agency continued to look for a provider who
offered family therapy services without success. The parents eventually received a
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referral from a provider and, in November 2025, were awaiting their first session.3
However, the Agency noted law enforcement had been called to the parents’ home based
on reports of an adult male and adult female fighting.
In September 2025, father reported he had overcome his aversion to being on
camera and would reengage in domestic violence services. The parents continued to live
together despite father’s minimal progress in services. In October 2025, the domestic
violence service provider reported that father had not spoken about his role in the
domestic violence, claiming instead to be a victim of his circumstances; he took no
ownership of his role in the domestic violence; he did not share how the minor not being
in the home affected the family; and he did not reflect on the domestic violence or
repairing his relationship with mother. The provider stated the parents may have ceased
physical abuse and transitioned to figuring out how to live in the same home with one
another, but father alluded to negative energy in the home and reported he and mother did
not talk to one another. The provider also reported father failed to demonstrate any
insight into his actions, was solely concerned about reuniting with the minor for the
betterment of the family and the parents’ other son, and did not recognize his part in why
the family came to the attention of the Agency. Mother was reported as likely to make
healthier choices, but family dynamics prevented her from leaving the home.
In December 2025, the Agency reported that father completed 12 sessions of
parenting class. He was participating in individual counseling through Dignity Health;
however, his counselor informed the Agency that no substantive information could be
provided due to “privacy laws” and father’s treatment was “not based on the CPS case.”
When the Agency learned this, it requested that father contact Dignity Health to request a
new provider who could provide the information required by the Agency. Father stated
3 Family therapy was eventually put on hold due to the divorce proceedings initiated
by mother.
4
he thought his record of attendance was sufficient and, in any event, he wanted to stay
with his current provider. The Agency requested father sign a more extensive release of
information so it could better assess the topics covered and the insight gained by father in
his current therapy.
In the meantime, the parents’ adult son reported mother and father argued every
day due to father “poking at [mother],” causing her to become upset and threaten to hit
him. Father had reportedly been contacting law enforcement to report strange events
such as the neighbors using a jammer to interfere with his security cameras, people
following him and possibly planning to kidnap him, people near the freeway having
something to do with mother’s kidnapping, and mother plotting against him. Law
enforcement advised father he would be connected with the police department’s mental
health team. Mother filed for divorce from father and moved out of the family home and
in with the maternal great-grandmother.
At the January 5, 2026, combined 6- and 12-month permanency planning hearing,
the juvenile court found return of the minor to his parents would create a substantial risk
of detriment. The court also found the Agency provided the parents with reasonable
services despite the issues associated with father’s individual counseling. The court
noted as to father that, “irrespective of the quality of the services, the issues with the
delivery of those services, … there is a lack of insight on the nature of the history of
domestic violence between mom and dad and how that has an impact on the [minor],
and … it appears there has been engagement in those services, but the insight is not there
yet.” The court ordered continued services to both parents and set the matter for an 18-
month permanency hearing.
Father appealed from the juvenile court’s January 2026 order.
In February 2026, the Agency reported mother was making substantial progress in
completing her case plan. On the other hand, father was making very little if any
progress in anger management and domestic violence services. He continued to deny and
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minimize the domestic violence, did not take responsibility for his role in it, and failed to
demonstrate insight into how his actions negatively affected the minor.
On March 3, 2026, the juvenile court granted the Agency’s section 388 petition for
modification and ordered the minor returned to mother’s custody with family
maintenance services to mother and discretionary services to father. The court also set an
interim review hearing for April 2026 and a six-month family maintenance review
hearing for September 2026.
At the April 2, 2026, hearing, the juvenile court ordered father to sign a release of
information regarding an outpatient program, confirmed the previously set family
maintenance review hearing, and vacated the 18-month review hearing.4
DISCUSSION
Father contends the juvenile court’s finding at the January 2026 hearing that
reasonable services had been provided is not supported by substantial evidence. He
claims the Agency failed to provide him with reasonable services (i.e., individual therapy,
family therapy, domestic violence and anger management classes, and visitation) from
the date the minor was placed in protective custody (November 6, 2024) and throughout
the following year.
The Agency argues the issue of reasonable services was rendered moot by the
court’s subsequent March 3, 2026, order returning the minor to mother with family
maintenance services and discretionary services to father and, in any event, the
reasonable services finding was supported by substantial evidence. As we explain, we
agree father’s claim is moot and will dismiss his appeal.
4 On July 30, 2026, the clerk of the juvenile court supplemented the appellate record
with the contested 12-month review order dated March 3, 2026, and the contested 18-
month review order dated April 2, 2026. We therefore dismiss as moot the Agency’s
July 1, 2026, request for judicial notice of those two orders.
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“A case becomes moot when events ‘ “render[] it impossible for [a] court, if it
should decide the case in favor of plaintiff, to grant him any effect[ive] relief.” ’ (Ibid.)
For relief to be ‘effective,’ two requirements must be met. First, the plaintiff must
complain of an ongoing harm. Second, the harm must be redressable or capable of being
rectified by the outcome the plaintiff seeks.” (In re D.P. (2023) 14 Cal.5th 266, 276; In
re S.R. (2025) 18 Cal.5th 1042, 1051 [parent must demonstrate a specific legal or
practical consequence that will be avoided by reversal].) “This rule applies in the
dependency context.” (D.P., at p. 276.) “A reviewing court must ‘ “decide on a case-by-
case basis whether subsequent events in a juvenile dependency matter make a case moot
and whether [its] decision would affect the outcome in a subsequent proceeding.” ’ ”
(Ibid.)
Here, father challenges the juvenile court’s January 2026 finding that the Agency
provided him with reasonable services. He requests that we vacate that finding and
remand with instructions to the juvenile court to find the Agency failed to offer him
reasonable reunification services and order that he be provided with additional
reunification services for a period of 12 to 18 months. Pursuant to the court’s January
2026 order, father continued to receive reunification services and was, therefore, already
receiving the remedy he requests. On March 3, 2026, however, the court ordered the
minor returned to mother with family maintenance services to mother and discretionary
services to father. Because the minor has already reunified with mother and the case is
now in family maintenance, father can no longer receive reunification services. (See
§ 361.6, subd. (a).) Thus, we cannot grant father any effective relief.
Relief is only effective “when it ‘can have a practical, tangible impact on the
parties’ conduct or legal status.’ [Citation.] It follows that, to show a need for effective
relief, the plaintiff must first demonstrate that he or she has suffered from a change in
legal status.” (In re D.P., supra, 14 Cal.5th at p. 277; In re S.R., supra, 18 Cal.5th at
p. 1051.)
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Although it appears the claim is moot, to the extent it could be argued that a
finding of reasonable services could be prejudicial to father should certain events occur in
the future, that is an argument father does not tender. Father does not identify any legal
or practical negative consequence that could result from the reasonable services finding
in this case, nor does he assert having suffered any consequence that could be addressed
upon reversal. Father elected not to respond to the Agency’s mootness argument, did not
argue his claim is not moot, and failed to assert how he would be prejudiced by the
court’s reasonable services finding.
While it is well settled that an erroneous reasonable services finding could impair
a parent’s request for more reunification services, thereby frustrating later attempts at
reunification, and could lead to a subsequent termination of parental rights (In re A.O.
(2025) 111 Cal.App.5th 1048, 1052), father has not shown he is in danger of any of these
potential consequences. Again, the court found the Agency provided father with
reasonable services at the January 2026 hearing and ordered continued services on its
own accord. Two months later, the court reunified the minor with mother under a plan of
family maintenance and ordered continued services to father. Father continued to receive
the services he seeks in this appeal and there is no pending threat that his parental rights
will be terminated without the provision of additional services because the case is in
family maintenance. “An appeal is prevented from becoming moot only if the rights of
the parties are directly affected by its determination. Their interest must be
‘immediate … and not a remote consequence of the judgment.’ ” (Consol. etc. Corp. v.
United A. etc. Workers (1946) 27 Cal.2d 859, 865, italics added, partly quoting Hamilton
Trust Co. v. Cornucopia Mines Co. (9th Cir. 1915) 223 F. 494, 499; see Libby, McNeil,
and Libby v. City National Bank (9th Cir. 1978) 592 F.2d 504, 511.) Therefore,
speculation about what might happen in the future in this case is not persuasive on the
question of mootness.
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We conclude father’s claim is moot. Even were we to find otherwise, our review
of the record convinces us that there is sufficient evidence to support the juvenile court’s
finding of reasonable services.
DISPOSITION
The appeal is dismissed as moot.
/s/
WISEMAN, J.
We concur:
/s/
HULL, Acting P. J.
/s/
RENNER, J.
Retired Associate Justice of the Court of Appeal, Fifth Appellate District, assigned by
the Chief Justice pursuant to article VI, section 6 of the California Constitution.
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